Worldwide: Transfer Pricing

In an article published in Insights in 2022, the following comment was made regarding two seemingly never-ending transfer pricing battles being conducted...

The One Big Beautiful Bill Act (OBBBA) is the latest sweeping change to the tax code—and one that advisors can't afford to ignore.

Aligning international tax strategy with global supply chain planning helps reduce tax exposure, capture incentives, and increase operational agility.

Riveron's M&A Tax and Transaction Services experts have observed the latest changes and evolving trends related to US trade and tariff policies and have participated in several discussions on the potential impacts.

The IRS has issued guidance endorsing a muscular approach to the application of "periodic adjustments" provisions. Those provisions authorize IRS adjustments of a taxpayer's pricing for transfers of high-value intangibles, including platform contribution transactions, for taxable years after the year of transfer, based on the actual, realized profitability of those intangibles in those later years

Federal courts next year are set to decide several cases that could shape how international tax planners will account for uncertainty and enforcement risks in 2025 and beyond.

Multinational groups constantly evolve, grow, and consolidate, and operational facts and circumstances always change. Say a growing company decides to expand internationally. It may choose to incorporate new...

On August 6, 2024, Treasury and the IRS released proposed regulations that address several long-standing issues related to dual consolidated losses (DCLs) and introduce new rules for "disregarded payment losses" (DPLs).

At the end of its 2023 term, the Supreme Court issued two opinions that will drastically change how taxpayers can challenge Department of Treasury (Treasury)...